Corrective Action Plans

Name of Auditee: Town of Union, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2024 CAP Prepared by: Jennifer Lindsay, Comptroller Phone: (607) 786-2931 (4) Audit Finding 2024-004 - The Town did not submit its audited financial information for the year ended December 31, 2024, to the FAC or to HUD via the FDS by the required deadlines. (a) Implementation Plan of Actions - The Town will work with MUNIS representatives to address specific challenges and expedite the resolution of technical system issues. (b) Implementation Date - This will be implemented for the year ending December 31, 2025. (c) Persons Responsible for Implementation - The Comptroller and the Town Board.

Management’s Response: Management will initiate controls to ensure that the funds from the calculation of the prior year surplus cash calculation are deposited in the residual receipts reserve for the year ended December 31, 2025.

Management’s Response: Management will initiate controls to ensure that the funds from the calculation of the prior year surplus cash calculation are deposited in the residual receipts reserve for the year ended December 31, 2025.

Management’s Response: Management will initiate controls to ensure that the funds from the calculation of the prior year surplus cash calculation are deposited in the residual receipts reserve for the year ended December 31, 2025.

Management’s Response: Management will initiate controls to ensure that the funds from the calculation of the prior year surplus cash calculation are deposited in the residual receipts reserve for the year ending December 31, 2025.

City will establish a clear policy with grant management firm to provide an opportunity for review and approval of monthly and quarterly reports to GLO.

Management concurs that reconciliation procedures can be strengthened. All accounting and reporting activities are performed using the Recipient systems, ensuring compliance with HUD reporting standards. Enhancements will focus on improving documentation and internal oversight.

Management acknowledges the recommendation and confirms that grant disbursements are processed using the systems and procedures established by the Recipient. Management is committed to reinforcing review processes to ensure proper documentation and oversight while remaining compliant with HUD requirements.

Management concurs with the facts presented by the auditor. However, we do not agree with the conclusion that there is a lack of adequate internal controls in the area of program reports and accounting records. The Bank, as a Subrecipient, performs the closing of the CDBG-DR SBF grants and records each transaction in a system provided by the Recipient and its consultants. The Administrative and Performance Reports referenced by the auditor are automatically generated from the grant management systems provided by the Recipient. The differences reflected between the Bank’s records and these reports result from a system error under the exclusive control of the Recipient and its consultants. These differences were duly reported to the Recipient and its consultants for correction.

Koinonia, Inc. Lenoir, North Carolina CORRECTIVE ACTION PLAN October 31, 2025 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Koinonia, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2024. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The finding from the year ended December 31, 2024 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING - Financial Statement Audit and Federal Award Program Audit Finding 2024-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend management review/enhance its accounting and internal control procedures to ensure that all key accounts are reconciled and reviewed with supporting evidence of such review. Action Taken: We agree with Finding 2024-001 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will review the accounting and financial procedures, system of internal controls and policies. If HUD has questions regarding this corrective action plan, please call 828-758-2617. Sincerely yours, Chassidy Triplett Project Administrator Koinonia, Inc.

Management will deposit required amounts.

BFCAC made a change in personnel during 2024. Subsequently, BFCAC has emphasized the need to maintain supporting documentation for all charges, including changes to timesheets, and supporting documentation for manual adjustments. The Executive Director and the Finance Manager are responsible for this corrective action.

CORRECTIVE ACTION PLAN August 13, 2024 U.S. DEPARTMENT OF EDUCATION U.S. DEPT. OF AGRICULTURE Purdy School District R-II respectfully submits the following corrective action plan for the year ended June 30, 2024. Contact information for the individual responsible for the corrective action: Dr Travis Graham, Superintendent Purdy School District R-II 201 Gabby Gibbons Dr Purdy, MO 65734 (417) 442-3215 Independent Public Accounting Firm: The CPA Group, PC, 217 4th Street, Monett, MO 65708 Audit Period: Year ended June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT Material Weakness – Internal Control over Financial Reporting - Segregation of duties Finding 2024-001 Recommendation: We realize Because of limited resources and personnel, management may not be able to achieve a proper segregation of duties; however, our professional standards require that we bring this lack of segregation of duties to your attention in this report. Action Taken: The limited number of available personnel prohibits segregation of incompatible duties and the District does not have the resources to hire additional accounting personnel. Completion Date: Not applicable Sincerely, Dr Travis Graham, Superintendent Purdy School District R-II

CORRECTIVE ACTION PLAN August 20, 2024 UNITED STATES DEPARTMENT OF EDUCATION UNITED STATES DEPARTMENT OF AGRICULTURE Southwest R-V School District respectfully submits the following corrective action plan for the year ended June 30, 2024. Contact information for the individual responsible for the corrective action: Dr. Tosha Tilford, Superintendent Southwest R-V School District 529 Pineville Rd Washburn, MO 65772 (417) 826-5410 Independent Public Accounting Firm: The CPA Group, PC, 217 4th Street, Monett, MO 65708 Audit Period: Year ended June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT Material Weakness – Internal Control over Financial Reporting - Segregation of duties Finding 2024-001 Recommendation: We realize Because of limited resources and personnel, management may not be able to achieve a proper segregation of duties; however, our professional standards require that we bring this lack of segregation of duties to your attention in this report. Action Taken: The limited number of available personnel prohibits segregation of incompatible duties and the District does not have the resources to hire additional accounting personnel. Completion Date: Not applicable Sincerely, Dr. Tosha Tilford, Superintendent Southwest R-V School District

2024-6 Segregation of Duties Recommendation: Ideally, the Borough would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the Borough's financial position.Management's Response: The Borough recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Assistant Borough Manager has to take an active role in the day-to-day operations of the Business Unit. She actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, Borough Council approves all disbursements.

Finding 2024-002: Insufficient Documentation of Management Review of Section 3 Quarterly and Annual Reporting Planned Corrective Action: Management agrees with the finding and will establish a formal review and approval process for all Section 3 quarterly and annual reports prepared and submitted by the grant administrator to the Texas General Land Office. Going forward, the City Secretary will review each report for accuracy and completeness prior to submission, and evidence of this review, such as signed approval or email confirmation, will be retained in the grant files. The City anticipates implementing this procedure for all future reporting periods to ensure compliance with federal reporting and internal control requirements. Anticipated Completion Date: December 2025

Corrective Action Plan Finding: 2024-005-Reporting Deadline Not Met-Reporting Condition: The audit report is being filed beyond the due date. Corrective Action Planned: We will comply with the auditor’s recommendation. Person responsible for corrective action: Louie Alfaro, Executive Director Telephone: (915) 886-4650 Housing Authority of the Town of Anthony, Texas Fax: (915) 886-2296 1007 Franklin Anthony, TX 79821 Anticipated Completion Date: September 30, 2025

Corrective Action Plan Finding: 2024-003-Lack of quality control and SEMAP-Eligibility and Special Tests Condition: The tenant files and waiting list were much improved over the prior year, for which numerous exceptions were noted. However, we did note the following: (a)-SEMAP was apparently not prepared by prior management. SEMAP is required by HUD regulations. This is a documentation that quality control was performed, broken down into subsets. Even if SEMAP was not required by HUD, at least similar documented quality control should be done and available for third party review. Statement of Auditing Standard #115, which auditors must follow, states “absent or inadequate segregation of duties within a significant account or process” is defined by the Standard as at least a significant deficiency or material weakness. Either require an audit finding. (b)-It appears that quality control inspections were not done. (c)-It appears that the last utility allowance review was done in August 2023. Federal regulations require that utility allowances be done annually. At least when any one category changes more than 10% since the last review, the allowances must be revised. Corrective Action Planned: We will comply with the auditor’s recommendation. Person responsible for corrective action: Louie Alfaro, Executive Director Telephone: (915) 886-4650 Housing Authority of the Town of Anthony, Texas Fax: (915) 886-2296 1007 Franklin Anthony, TX 79821 Anticipated Completion Date: September 30, 2025

Corrective Action Plan Finding: 2024-002-Administration of the Homeownership Program and FSS Programs Need Improvement-Special Tests Condition: FSS A recently hired case worker is adequately tracking three participants in the program. However, two participants have graduated. They should be notified that they are due funds if they elect to draw them now. The liability to the two tenants at September 30, 2024 is a total of $3,976. In addition, there is no documentation in the files that recent new people to the program were made aware that if they chose to, they could participate in the program Homeownership For the last several years, the various E.D.s have asserted that they were behind in updating the status of Homeownership participants. They provided no lists of enrollees. However, in the current audit period, a case worker has found a list dated September 30, 2015 of 13 participants. A review has found an additional enrollee. The review has determined that of the 14 total, 6 are no longer on the program. The status of the other eight is presently not known. Corrective Action Planned: We will review all of the above at our next board meeting. But initially, I agree with the above recommendations. Person responsible for corrective action: Louie Alfaro, Executive Director Telephone: (915) 886-4650 Housing Authority of the Town of Anthony, Texas Fax: (915) 886-2296 1007 Franklin Anthony, TX 79821 Anticipated Completion Date: September 30, 2025

ANTHONY HOUSING AUTHORITY PHONE: 915-886-4650 ·FAX:915-886-2296 1007 FRANKLIN ANTHONY, TEXAS 79821 HOUSING AUTHORITY OF ANTHONY, TEXAS CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2024 Corrective Action Plan Finding: 2024-001-Inadequate Accounting and Documentation-Allowable Costs/Principles and Reporting Condition: The outside fee accountant delivered a letter dated November 30, 2024 that outlined the significant issues that management needed to address before the fee accountant could sign off on their year- end checklist regarding the unaudited financial statements. The fee accountant never received the information that would allow them to sign this checklist. With the accompanying daily operational issues the new Executive Director encountered, he was unable to give sufficient attention to the issues noted by the fee accountant, as outlined in their November letter. The financial statements were misstated, including the following: (a)-The Housing Check Voucher operating bank statement reflects an overdraft of $195,295, which includes approximately $252,818 of outstanding checks. These checks were dated from February 1, 2022 through September 1, 2024. Only $45,768 of these checks were dated from July 20, 2024 forward. (b)-The accounting records reflect an account payable of $255,086 for the General Fund- Low Rent program, owed to the HCV Program. $ 88,324 of this amount consists of Ross Grant funds received by the Low Rent program that should have been utilized by the Housing Choice Voucher (HCV) Program. The accounting records reflect that the remaining balance is owed to the HCV Program for various expenses, principally $76,700 for payroll and $39,500 for software. This $255,086 is incorrectly reflected as accounts payable, instead of interfund due to the HCV Program. The HCV program incorrectly shows an accounts receivable of $42,859, which is coded as only part of the $88,324 (see above), owed to HCV by the Low Rent Program. Instead of payables and receivables, these amounts due to HCV Program by the Low Rent program should be reflected as interfund receivables and payables, and the amount should equal. (c)-At September 30, 2024, the Authority had fully expended recent Ross Grants of $39,045 and $57,394. On September 23, 2024 the bank statement reflected a deposit of $41,144 labeled “HUD ROSS.” Management has been unable to give us a copy of the original grant agreement or other details of this grant. (d)-The HCV Program paid $3,131,825 in electronic payments. The Low Rent Program, via the General Fund, paid $15,009 in electronic payments. It appears the type of written second approval that we have recommended for multiple years was not used. Only the Executive Director appears to have initiated and completed these purchases. We were unable to review the supporting detail such as invoices or statements, except for 9 of 296 transactions in the HCV Program that totaled $1,721 and 16 of 78 in the Low Rent program that totaled $5,310. We note that almost all Authority expenses were paid in this manner. This includes payroll, HAP payments, and utilities. We noted payments coded mainly to Contract Materials that were paid to Walmart, Amazon, Sam’s Club, and Pilot. Travel expenses appear to be unusually high for a small, financially trouble Authority. (e)-Government Accounting Standards Bulletin (GASB) 96, a relatively new pronouncement, addresses subscription-based technology arrangements. The Authority utilizes a subscription software that performs various functions related to tenant files, waiting lists, and various reports to HUD. Since the Authority’s current agreement is for multiple years, a significant accounting adjustment should have been recorded on the general ledger, but was not. (f)-As detailed in Note 11 of the financial statements, the Authority participates in a Simplified Pension Plan (SEP). We have requested in prior years from management a copy of the board resolution, or some other documentation, that details the percentage to be contributed. We have still not received that documentation. Prior management claimed this percentage to be 8%. (g)-The fee accountant in their November 2024 letter requested clarification of $126,982 of deferred CARES Act funds. We believe this deferred amount is in error on the financial statements. In our opinion, $60,964 should have been reported as Admin and Tenant Services salaries for the audit year September 30, 2020. The remaining CARES Act funding of $66,018 should been reported as Tenant Services salaries for the years ended September 30, 2020 and 2021. Corrective Action Planned: I am Louis Alfaro, Executive Director and Designated Person to answer these findings. We will comply with the auditor’s recommendation. As noted above, I did not become Executive Director until after this audit period. Person responsible for corrective action: Louie Alfaro, Executive Director Telephone: (915) 886-4650 Housing Authority of the Town of Anthony, Texas Fax: (915) 886-2296 1007 Franklin Anthony, TX 79821 Anticipated Completion Date: September 30, 2025

Name of Auditee: City of New Rochelle, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2024 CAP Prepared by: Edward Ritter, Commissioner of Finance Phone: (914) 654-2000 (3) Audit Finding 2024-003 - the City did not timely submit the Federal Data Collection Forms to the appropriate authorities. (a) Implementation Plan of Actions - Management has contracted with a third party to assist with entering and submitting the required years of the Federal Data Collection Form for the City’s Section 8 Housing Choice Voucher Program for fiscal years ended December 31, 2021 and 2022. Management has contracted with their external auditors to perform the submissions of the Federal Data Collection Forms for fiscal years ended December 31, 2024 and 2023. These forms will be submitted in chronological order once they are processed by the U.S. Department of Housing and Urban Development. Additionally, management has contracted with another third party to provide assistance with the year-end closing procedures. Such assistance may enable management to ensure that the Federal Data Collection Form is submitted to the Federal Audit Clearinghouse by the required deadline. (b) Implementation Date - This will be implemented during the year ended December 31, 2025. (c) Persons Responsible for Implementation - The Commissioner of Finance, Commissioner of Development and the City Council.

CORRECTIVE ACTION PLAN October 23, 2025 Town of Blacksburg, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2024-002: CDBG – Community Development Block Grants/Entitlement Grants – ALN #14.218, Reporting Condition: Housing and Community Connections did not timely file Cash on Hand Quarterly Reports in two instances of testing. Criteria: Under the requirements in the Uniform Guidance, reports are to be filed within 30 days after the end of the reporting period. Cause: Housing and Community Connections typically file all reports timely, however, two quarterly reports during the same quarter were filed late. Effect: Failure to file timely reports could result in improper reporting of the use of Federal funds. Perspective Information: Two Cash on Hand Quarterly Reports of four tested were not filed within 30 days after the end of the reporting period. Recommendation: Management should implement a procedure to ensure that reports are filed within reporting periods. Views of Responsible Officials and Planned Corrective Action: To address this finding, Housing and Community Connections has taken the following steps: 1. Compliance Calendar & Reminders – Staff have implemented calendar reminders for all HUD reporting requirements. Reporting deadlines are also reviewed at bi-monthly staff meetings to ensure awareness of upcoming due dates. 2. Defined Roles and Responsibilities – The HOME/CDBG Program Coordinator now assembles applicable data and prepares a draft of each quarterly Cash on Hand Report. This draft is reviewed with the Housing and Community Connections Manager before submission. 3. Approval and Retention Process – A final review and approval is conducted by the Manager prior to submission. Copies of all submitted reports are retained in office files as part of our strengthened workflow. FINDINGS – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2024-003: CDBG – Community Development Block Grants/Entitlement Grants – ALN #14.218, COVID-19 Coronavirus State and Local Fiscal Recovery Fund – ALN #21.027, Late Filing of Financial Report and Data Collection Form Condition: The Town did not submit the data collection form or financial report for the year ended June 30, 2024 timely. Criteria: For June 30, 2024, year-end audits, under the requirements in the Uniform Guidance and the Office of Management and Budget (OMB), all entities are required to submit the annual data collection form with the Federal Audit Clearinghouse the earlier of either 30 days after the issuance of the entity’s annual audit or nine months after the entity’s fiscal year end. Cause: Management did not complete and certify their portion of the form before the deadline. The form cannot be completed before the audit is issued. Effect: The Town’s form was submitted to the Federal Audit Clearinghouse late, delaying completion of all annual audit requirements for the Town. Recommendation: Management should take steps to ensure that the form and financial report are filed timely. View of Responsible Officials and Planned Corrective Action: To address this finding, the Town has strengthened internal processes to ensure timely submission of all future financial reporting and audit certification materials through the following measures: 1. Submission Tracking and Deadline Control – A centralized federal reporting tracker has been created to monitor all post-audit submission requirements. The Housing and Community Connections Manager will receive automated deadline reminders beginning 30 days before each reporting due date. 2. Defined Accountability Chain – The Town Manager’s Office and the Finance Department are responsible for completing and certifying the data collection form promptly upon issuance of the audit. The Housing and Community Connections Division will verify completion and coordinate any supplemental financial information required for submission. 3. Post-Audit Compliance Review – A post-audit checklist has been developed to confirm all required submissions – including the Federal Audit Clearinghouse filing – are completed and documented. Completion status will be reviewed in the first Finance/Housing coordination meeting following each audit. If the Federal Audit Clearinghouse has questions regarding this plan, please call Jeff Lazenby, Director of Finance at 540-443-1051. Jeff Lazenby Director of Finance

Reasonable Rent Review Planned Corrective Action: The Continuum of Care (CoC) program was transitioned to another organization during FY2024 as part of a broader realignment of programs and services. Heartland Alliance Health no longer administers this program, and all compliance responsibilities, including tenant files and rent documentation, were transferred to the receiving entity. At the request of the auditors, Heartland Alliance Health has initiated contact with the new organization to confirm that all required program and tenant records have been properly transferred, secured, and maintained in compliance with HUD regulations. Person Responsible for Corrective Action Plan: Steve Knox, Controller Anticipated Date of Completion: Resolved

Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2025.

Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2025.